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Got to talk to someone from FREAB today

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Roger Kinnard

Sophomore Member
Joined
Jan 29, 2005
Professional Status
Certified Residential Appraiser
State
Florida
Mike Rogers, the vice chair of FREAB came by and gave a talk to our local association of realtors appraisal committee today.

It was an interesting session. He is very much an advocate of appraisers (anti AVM and AMC) and has a first hand understanding of the situation that we are faced with today. I was impressed by his honesty with us and I'm glad he is on the board.

The majority of our membership is comprised of residential appraisers who primarily do mortgage work. He made it very clear to us that we are targets and that we need to act a little paranoid. He explained the process involved when dealing with complaints and made some good suggestions about how to protect yourself when, not if, it happens to you. He said they are expecting around 1500 complaints over the next year, almost double from the previous year. He advised us all to take some extra time to make sure that our files were as bullet proof as possible and detailed some things that the invesigators are looking for.

Some items of interest he specified

- Be as honest and forthright as possible when dealing with the invesigators. They are trained to catch on to any sort of dissembling and react aggressively when they sense that they are not being told the entire truth.

- Get a lawyer immediately when you get the dreaded letter, preferably one that is skilled in admistrative law. He even noted several that they saw repeatedly that were very good at handling this sort of case.

- Make copies of your M&S pages and keep them in the file. Not an absolute neccesity, but better than trying to reproduce your numbers while an investigator is standing over your shoulder.

- When making a correction on an appraisal, make another file and reference the previous file.

- Summarize your HBU analysis, even if it's obvious. They haven't dinged any one on that yet, but they will in the future.

- Document, document, document everything as if every appraisal that you write is going to be looked at by the investigators. Be as transparent as possible.

- Make a note in the appraisal about every adjustment. Even if it's for bathroom count. Also note non adjustments like a difference in site size of less than 10%.

- When sending a report through a portal that breaks up the report, we are still very much responsible for the end result.

All in all, it was a great learning experience. As someone who has had a complaint filed against them (dismissed at probable cause), I've had some insight into what is involved & the anxiety that you go through, even if you know that you did nothing wrong. The purpose of FREAB is to protect the public through ensuring compliance and knowing how to comply and what they are looking for makes it much easier.
 

Francois K. Gregoire

Senior Member
Joined
Jan 14, 2002
Professional Status
Certified Residential Appraiser
State
Florida
Mike is a good guy and very fair. He is a very good addition to the Florida Real Estate Appraisal Board. You will find him untolerant of inadequate supervision and tough on supervisory appraisers that shirk their responsibility for training and supervision.

It's a good thing the Governor appointed someone from the panhandle, but the travel is tough on Mike. That's a 450 mile trip to Orlando.
 
Joined
Jan 13, 2002
Professional Status
Retired Appraiser
State
Florida
I really like Mike Rogers and believe Frank's assessment is correct.

This needing a copy of each Marshall & Swift page used needing to be in each and every workfile is over the top -
and, what are they going to do with the online M&S version?
IMHO, FREAB investigators and staff really do need to back off on this issue as the majority of appraisers have never done that, except for the old FHA appraisals.
They should check to see if the appraiser has a 'used' M&S issue / pages in effect for the time period of the appraisal in question, and if the appraisal in question matches the information on those pages and/or has supplemental local builder data that makes the cost approach make sense - or that the printout from the online M&S is in workfile.
 
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